titre fg interoperability & data exchange rules meeting guide 3 rd ad hoc expert group meeting...

TITRE

FG Interoperability & Data Exchange Rules

Meeting guide

3rd Ad Hoc Expert Group meetingVienna, 11 June 2012

Agenda Topics10:30 – 10:40 1. Welcome & agenda of the day

10:40 – 12:00 2. Presentation of Pöyry :

“Interoperability Framework Guideline Impact Assessment Analysis"

12:00 – 13:00 Lunch

13:00 – 16:00 3. Draft Framework Guideline discussion

Based on the outcome of the consultation

16:00 – 16:15 4. Other issues to be addressed

15:15 – 16:30 5. Conclusions of the day

Agenda

INTEROPERABILITY & DATA EXCHANGE

11 June 2012 – 3rd Ad Hoc Expert Group, Vienna

Update on consultancy study

• Launch of the study on 2 April 2012;

• Kick off meeting on 10 April 2012;

• Skeleton report on 27 April 2012 – to discuss the

structure;

• Draft Final report delivered just before midnight on

8 June;

• Deadline for Final report 15 June 2012.



Objectives of the study

The purpose of this study is to assist ACER in preparing an impact assessment for the Framework Guideline on Interoperability Rules:

•Collect and present quantified evidence and data, for the problem identification exercise;

•Evaluate the policy options;

•Create a coherent view;

•Recommend key design elements to base interoperability rules on;

•Propose a roadmap for implementation;



Agenda Topics10:30 – 10:40 1. Welcome & agenda of the day

10:40 – 12:00 2. Presentation of Pöyry :

“Interoperability Framework Guideline Impact Assessment Analysis"

12:00 – 13:00 Lunch

13:00 – 16:00 3. Draft Framework Guideline discussion

Based on the outcome of the consultation

16:00 – 16:15 4. Other issues to be addressed

15:15 – 16:30 5. Conclusions of the day

Agenda



Consultation - General outcome


• From 16 March 2012 to 16 May 2012, the Agency ran a public consultation on the draft FG on Interoperability and Data Exchange Rules.

• The consultation resulted in a total of 34 responses:


34 Respondents :

BDEW ENI adriaplin GIECEDEC ENTSOG GMTDEPA EURELECTRIC GTG Nord

EASEE gas EUROGAS IFIEC/CEFIC

EDISONEUROGAS

distribution JP MorganEDF EUROMOT MARCOGAZEDP EXXONMOBIL National GridEFET GasLink Statoil

Enagas GasNatural Fenosa OGPENBW GEODE VENENEL GDF SUEZ VNGENI



Questions on Scope and application:

INTEROPERABILITY & DATA EXCHANGEFOUNDING’S


Question 1.1 : Do you consider that the FG on interoperability and data exchange rules should harmonise these rules at EU level, as follows:

•At interconnection points only?

•Including interconnection points and where appropriate points connecting TSOs’ systems to the ones of DSOs, SSOs and LSOs (to the extent cross-border trade is involved or market integration is at stake)?

•Other option. Please explain in detail and reason?

• I don’t know

• 11

• 19

• 2

• 0

Answers




Question 1.2 : Do you consider that for any of the above options the level of harmonisation shall be (Section 1.b of the FG):

•Full harmonisation: the same measure applies across the EU borders, defined in the network code?

•Harmonisation with built-in contingency: same principles/criteria are set with a possibility to deviate under justified circumstances?

•No additional harmonisation, meaning rules are set at national level, if they deemed necessary by the national authorities, which may include either NRAs or the government?

• 10

• 14

• 1

Answers




Question 1.3 :Shall any of the issues raised in the FG (Interconnection Agreement, Harmonisation of units, Gas Quality, Odorisation, Data exchange, Capacity calculation) get a different scope from the general scope as proposed in section 1.b. of the FG (and as addressed in the previous question)? Please answer by filling in the following table, ticking the box corresponding to the relevant foreseen scope.

IAs Units Gas Quality Odorisation Data Exchange

Capacity Calculation

Full harmonization 9 24 7 10 20 9

Partial harmonization 16 3 19 10 6 12

Business as usual 8 0 3 8 2 5




Question 1.4: What additional measures could you envisage to improve the implementation of the network code? Please reason your answer.

•look for a trade off between an adequate timeline for the implementation of the Network Code for operators and network users;

•ensure for a high level of transparency in each step of the Network Code development, both with consultation procedures and with a clear description of reasons for the options chosen;

•harmonise the communication on works on transmission networks.

Interconnection Agreements (IAs):



Question 2.1: Will a common template and a standard Interconnection Agreement do the trick?•Yes;•No; •I don’t know.•Would you propose additional measures? •Would you propose different measures?

•support from 8 without remarks, 8/10 with additional measures;

•different measures are expressed :• drop the standard IA;• limit the intervention of NRAs;• limit the scope of the standard IA on certain topics only;• limit an IA to TSO-TSO operational rules.

• 8• 0• 1

• 10•8

Answers




Do experts see a problem in defining a model template for IA and a standard IA on the following topics:

•Development and Modification of interconnection agreements

•Rules for flow control;

•Measurement principles of gas quantities and quality;

•Matching;

•Rules for the allocation of gas quantities;

•Exceptional events;

•Dispute resolution between TSOs?

Did we overlook effect on connections with non-EU Member States and/or DSOs (excluding matching and allocation?




What do experts think about the following additions:

•responsibilities for the management of metering and meter reading activities

•the selection, for any IP, of a single point of metering;

•include a non-exhaustive list of gas quality parameters;

•coordinate on maintenance plans (as stated in NC CAM);

•make allocation rules transparent to the market;

•include a definition of “exeptional event”;

•require TSOs to act as reasonable and prudent operators at all times

•account for “fuel gas”.




Question 2.2: Is the dispute settlement procedure OK?•Yes;•No; •I don’t know.•Would you propose additional measures? •Would you propose different measures?

•support from 13 respondents to the measure;

•main objection: the procedure is related to the national legal system agreed and shippers can always call on the national regulatory authority in charge of energy issues;

• 13• 1• 2• 2•7

Answers




What do experts think about the following additional measures asked in relation to the dispute settlement procedure:

•the installation of a timely and efficient dispute procedure;

•a consultation on its design;

•delays to be set clear;

•detailed rules in Framework Guideline and Network Code and the consequence for the agreements with non-EU member states is to be reflected on?




Question 2.3: Do you want stronger NRA involvement in the approval of the IA? •Yes;•No; •I don’t know.

•support from 16 respondents measures;

•To include another 4 if the stronger involvement of NRAs, and in last resort ACER, is limited to specific situations, e.g. if the TSOs have difficulty in reaching an agreement;

• 16• 8• 2

Answers

Units:



Question 3.1: Do you think that there is a need for harmonisation of units?•Yes;•No; •I don’t know.•Would you propose additional measures? •Would you propose different measures?

•Can standardised conversion rules or conversion factors (to be specified including the decimal factors to be used) stand in as an alternative? (TSO-TSO);

• How to decide on the timing of the introduction of harmonised units in conjunction to other interoperability harmonisation, such as IT systems?

• 27• 1• 0• 0•1

Answers

Units:



Question 3.3: Shall harmonisation be extended to other units? •Yes;•No.

• gas quality and quantity parameters are suggested;

• the use of the euro for information is proposed;

• the publication of an official conversion table is asked.

Several respondents ask for a supplementary rule to use units in a consistent way throughout the logistic chain of TSO services, from capacity booking till allocation of gas.

• 12• 11

Answers

Gas Quality:



Question 4.1 - Please provide your assessment on the present proposal; in particular assess the provisions on ENTSOG gas quality monitoring, dispute settlement and TSO cooperation?

19 out of 33 responses assess positively one or more parts of the current proposal.

Detailed modifications to the text are proposed :

• to protect shippers from extra charges and contract change;

• to mention gas quality also in the IA;

• to set the rules on interconnection points;

• to reconsider the implementation time.

Gas Quality:



What do experts think about the following positions:

• The information provision should be tackled at national level, because:

• not all TSOs have direct obligations with end users;• the need for such a service is likely to vary based on the types of industrial consumers that are connected to a TSO’s network;• depends on relatively wide or relatively narrow national quality specifications;• possible confidentiality issues;

•Questioning the feasibility of the gas monitoring, because data is held upstream and sometimes confidential;

Odourisation:



Question 5.1 Please provide your assessment on the present proposal. Would the measure proposed address sufficiently the issues that are at stake? Please reason your answer?

21 out of 30 responses agree that there is an issue with odourisation.

How is the role of Member States to be defined?

Is the measure useful if reassurance is given that the default rule (non-odourised gas at IPs) shall not be approved while there is not any evidence for the need of it? How to define “evidence” and who to be set responsable?

Data Exchange:



Question 6.1.: Please provide your assessment on the present proposal. Would the measures proposed address sufficiently the issues that are at stake? Please reason your answer?

16 out of 24 associations or companies assess the present proposal positively.

How do we look towards:

• one unique communication platform for the whole of Europe;

• to harmonise on content;

• to be specific on the timescales for implementation (in conformity with the other Framework Guidelines)

Data Exchange:



Question 6.2.: Regarding the content of this chapter,

... b. Data exchange shall define both format and content, at least regarding the following points: ______________(21/26).

• Specific points are given;

• Or reference is made to other FG/NC;.

How to decide on including content >< flexibility?

How to position voluntery rules >< binding rules?

Capacity Calculation:



Question 7.1 Please provide your assessment on the present proposal. Would the measures proposed address the issues that are at stake?

Is there support including in the Framework Guideline a common approach to the capacity definitions (baseline, technical, additional and interruptible) in accordance with paragraph 3.3 of Annex 1 to the Gas Regulation?

• Expending the rules also to additional and interruptible;

Is it helpful to focus more for a joint calculation of capacity, using a single model, aiming to reproduce what an ISO would do if they had responsibility for both systems and an obligation to maximize the capacity that could be offered?

Next Steps

11/06: Ad Hoc Experts group meeting & Meeting with Pöyry

12/06: Task Force meeting – Finalisation of Framework Guideline text according to consultation comments

21/06: Task Force deadline for :

Evaluation of Comments paper;

Impact Assessment paper

Final Framework Guideline text

31/07: ACER deadline to finalise the Framework Guideline process



titre fg interoperability & data exchange rules meeting guide 3 rd ad hoc expert group meeting...

Documents

expert group meeting

experts group meeting

framework guideline

vienna question

capacity calculation

voluntery rules

joint calculation of

task force deadline